An SVHC is confirmed in your article. Which duties do you owe — and by when?
Once a Candidate List substance of very high concern is above 0.1% w/w in your article, three duties can arise — and one runs on a 45-day clock. Answer three questions to see who you owe each duty to and the deadline.
- Trigger threshold
- 0.1% SVHC by weight (w/w) of the article
- Consumer reply clock
- 45 days Art 33(2), free of charge, on request
- Possible duties
- 4 Art 33(1) · Art 33(2) · Art 7(2) · SCIP
SVHC duty verdict
Both — Article 33 + SCIP
You owe both the REACH Article 33 safe-use communication and the SCIP notification to ECHA. See the two duties below.
Who you owe, and by when
REACH Art 33(1) — supply-chain info
OWEDPass safe-use information — at least the name of the SVHC — to anyone you supply the article to. No request needed; it travels with the goods.
REACH Art 33(2) — consumer request
OWEDIf a consumer requests it, give the safe-use information within 45 days, free of charge — at least the substance name. This is the duty on a clock.
REACH Art 7(2) — notify ECHA
OWEDA separate notification to ECHA applies only if the SVHC is present above 0.1% w/w AND above one tonne per year across your articles, within 6 months of the substance being added to the Candidate List. Check the tonnage yourself — this tool does not.
SCIP notification — notify ECHA
OWEDSubmit information on the article to ECHA's SCIP database so it is available across the product lifecycle, including the waste stage. Mandatory since 5 Jan 2021.
The four duties once an SVHC is confirmed >0.1% w/w
If an article you place on the EU market contains a Candidate List SVHC above 0.1% weight by weight, REACH and the Waste Framework Directive can put up to four duties on you. Each is owed to a different recipient and carries its own deadline.
| Duty | Owed to | Deadline / timing |
|---|---|---|
| REACH Art 33(1) — supply-chain information | Professional recipients of the article | Automatically, with delivery — no request needed |
| REACH Art 33(2) — consumer request | A consumer who asks | Within 45 days, free of charge |
| REACH Art 7(2) — notify ECHA | ECHA (substances in articles) | If >0.1% AND >1 t/yr: within 6 months of the substance being listed |
| SCIP notification | ECHA (SCIP database) | Before placing on the EU market — mandatory since 5 Jan 2021 |
Art 33(1) is automatic to professional buyers; Art 33(2) is the one on a clock — a consumer request must be answered within 45 days, free of charge, naming at least the substance. Art 7(2) notification to ECHA bites only above both 0.1% w/w and 1 tonne per year, within 6 months of listing. SCIP applies on EU-market placement unless the direct-to-consumer retailer exemption covers you.
Official sources: ECHA — Candidate List obligations · ECHA — Notification of substances in articles (Art 7(2)) · ECHA — SCIP · REACH (EC) 1907/2006
SVHC duty rules last reviewed June 2026.All rules verified against ECHA and EUR-Lex (2026-06-14).
What this tool is — and isn't
This checker resolves which SVHC duties (REACH Article 33 and/or SCIP) apply from the facts you enter, using ECHA + EUR-Lex guidance. It is an estimate and orientation, not legal advice, and it does not check the Candidate List for you, determine concentrations, or cover separate Article 7(2) notification of substances in articles. Verify against the linked official sources.
Proposed change — not yet law
On 10 December 2025 the European Commission proposed, in its Environmental Omnibus package (COM(2025) 986), to repeal the SCIP notification obligation by amending the Waste Framework Directive. As of June 2026 this is only a proposal: it has not been adopted by the European Parliament and Council, so SCIP notification remains legally required. REACH Article 33 is not affected by this proposal. This tool reflects the law currently in force; if the repeal is adopted, the SCIP result will be updated.
How the determination works
1. Is there an SVHC above 0.1%?
The duties only bite if your article contains a Candidate List substance of very high concern above 0.1% weight by weight. The tool asks you — it does not check the list for you.
2. Article 33 communication
If you supply the article on the EU market, Article 33 requires you to pass safe-use information (at least the substance name) to recipients, and to consumers on request within 45 days, free of charge.
3. SCIP notification + the retailer exemption
On top of Article 33, you must notify the article to ECHA's SCIP database — unless you are an EU retailer supplying directly and exclusively to consumers and not an importer, in which case SCIP does not apply but Article 33 still does.
Frequently asked questions
What is the 0.1% threshold?
Both duties bite when a Candidate List SVHC is present in the article above 0.1% weight by weight (w/w). Below that, these provisions are not triggered.
What does Article 33 require?
Sufficient information to allow safe use of the article — at least the name of the SVHC — to recipients, and to consumers on request within 45 days, free of charge.
What is SCIP?
The Substances of Concern In articles database at ECHA. Suppliers placing articles with SVHCs above 0.1% w/w on the EU market notify SCIP so the information is available across the product's lifecycle, including waste.
I'm a shop selling only to consumers — do I notify SCIP?
No, if you supply directly and exclusively to consumers and are not an importer, the SCIP retailer exemption applies. But REACH Article 33 still requires you to give consumers the safe-use information on request.
Since when is SCIP mandatory?
SCIP notifications have been required since 5 January 2021, under the Waste Framework Directive.
Is this legal advice?
No. This tool resolves which duties apply from your inputs. It is orientation, not legal advice, and does not check the Candidate List or determine concentrations. Verify against the linked official sources.
Isn't the SCIP database being scrapped?
The European Commission has proposed repealing the SCIP notification obligation (Environmental Omnibus, COM(2025) 986, 10 December 2025), but as of June 2026 this is only a proposal — it has not been adopted by the European Parliament and Council, so SCIP notification is still legally required. REACH Article 33 is not affected. This tool reflects the law in force and will be updated if the repeal is adopted.